West Goshen Risk Assessment Breakdown Pt. 1

A risk assessment conducted by Accufacts Inc., using industry sensitive information from Sunoco, was recently released and presented to the public. The study specifically evaluated potential risk from the 12-inch supplemental line being used to move natural gas liquids eastward between portions of Mariner East 2 and Mariner East 2X through West Goshen Township.

The assessment found: “As discussed further below, the 12-inch pipeline meets or exceeds federal pipeline safety regulations for HVL liquid transmission pipeline service.” Reiterating what Sunoco and Energy Transfer have long guaranteed about their natural gas pipelines.


Accufacts specializes in technical and safety evaluation and planning for pipeline siting, design, operation, maintenance, emergency response, and regulatory requirements. The firm has previously been retained to conduct risk assessments in Pennsylvania. Accufacts worked alongside the West Goshen Township legal team and Sunoco to draw up a Nondisclosure Agreement so that corporate specifics about the pipeline could be accounted for in their study. Accufacts admitted that pipeline differences such as diameter factor into risk and deemed industry specifics necessary to complete a thorough assessment.

Supplemental Line Facts:

  • 24 miles of an existing 12-inch line will be used to interconnect a western portion of ME 2 and an eastern segment of ME 2X, which is 16 inches in diameter.
  • End destination is the Sunoco Marcus Hook facility
  • The supplemental line does not use any pump stations
  • Will carry 150 to 160 MB/D of butane or propane liquids

Pipeline Integrity and Safety Measures:

Accufacts notes that though the pipeline was installed in 1937 of seamless Grade B steel the risk of cracking or a loss of pipeline integrity is overstated. In fact, the report provides the following: “As mentioned in previous reports, pipe steel, even pipe steel manufactured over 80 years ago, does not age or wear out like some older materials such as cast or wrought iron that can be “age” sensitive. Pipe steel has essentially an infinite life if properly maintained and operated within its design parameters, and periodically assessed as to its integrity.

Pipe age is a poor risk predictor and many of the nation’s older pipes are more resilient to hydrostatic testing because of safety factors during manufacturing.

Accufacts concluded that Sunoco went above and beyond the standard safety measures required by state and federal regulators through the use of hydrostatic testing and ‘smart pigs’ – devices used to scan the integrity of the inside of pipelines. Additionally, another round of hydrostatic and ‘smart pig’ tests were run for added certainty.

As an added layer of security Sunoco has agreed to convert the manual valve station controlling the supplemental line to be compatible with remote functions and like Mariner East 1 and 2 an automatic pipeline shutdown feature has been incorporated. All of these measures sum to show the township, and broader state of Pennsylvania, that safety and security are the top priority.


Richard Kuprewicz, the President of Accufacts, signed off on the report officially determining the supplemental line through West Goshen Township to be safe and that “Sunoco meets and exceeds the requirements of federal pipeline safety regulations. These additional precautions reflect the level of respect that transporting such materials in a HCA should require in a prudent pipeline operation. Accufacts thus concludes that the 12-inch Repurpose Project spanning WGT meets or exceeds the prudent technical approaches commensurate with the safe transportation of HVL.

Pipeline Activists’ Frivolous Suit Fell Short

The latest desperate attempt to halt the Mariner East 2 pipeline system through the courts has failed.

In November, seven residents from Chester and Delaware counties filed complaints to the Pennsylvania Public Utility Commission against Sunoco Pipelines. The complaints claimed that the Mariner East pipelines carrying liquid natural gas presented an intolerable amount of danger and must be stopped through an ‘Interim Emergency Order.’

The courts have finally spoken on the issue, writing:

“In conclusion, Petitioners/Complainants have failed to demonstrate by a preponderance of the evidence that they have met all four requirements and are entitled to emergency interim relief pursuant to 52 Pa. Code § 3.6.  Petitioners have not satisfied any of the four requirements.  Accordingly, the relief requested will be denied in the Ordering paragraphs below.”

Pipeline opponents were unable to meet any of the four requirements that justify an emergency order. The success (really a lack there of) falls in line with the baseless arguments pipeline opponents have relied on in hopes of stopping an infrastructure project critical to Pennsylvania’s economic success.

MDN Highlights Bias In Latest Hearing and Media

Last week Judge Elizabeth Barnes – the same judge for the Pennsylvania Public Utility Commission that shut down construction of the Mariner East 2 project in May, only to have the order overturned by the PUC – presided over a case brought by a few landowners in Chester and Delaware counties as a last-ditch effort to use the legal system to halt the Mariner East project. The complaint at issue has already been upheld by the PUC as a whole, as well as the courts on multiple occasions.

Jim Willis of Marcellus Drilling News was quick to point out the biased reporting by the anti-pipeline funded State Impact Pennsylvania and reminded readers that Judge Barnes previously ruled against the pipeline in a gross display of “arrogance and seizure of power” that she seems likely to abuse again.

Judge Barnes is expected to announce her decision by December 10th or 11th where it will then proceed to the Commission itself later in the month. Barnes’ May decision was unanimously overturned and if she rules again based off of personal bias as opposed to legal foundation, we hope she is overturned again. Judges usually don’t like to be overturned, but judgement clouded by ideology sometimes trumps doing the right thing.

Thanks to Jim Willis for presenting facts around this case. Despite claims by the litigants that first responders have not been trained, Willis reminds readers that Sunoco, as part of their Mariner Emergency Responder Outreach program, trained 2,350 firefights, police offices, and first responders across municipalities on pipeline safety protocol and management.

This case is just a last ditch effort by pipeline opponents to shut down a legally permitted project on faulty arguments.

Professional Risk Assessment Study Provides Accuracy and Relief

Delaware County Council’s pipeline risk assessment study results were featured in a Delco Times article today. These assessments seem to be published with growing frequency though today’s was the work of professionals.

The Delaware County Council should be commended for selecting G2 Integrated Services, a Houston based infrastructure compliance and risk management firm, and adding a professional perspective to a discussion that has had many self-interested voices at play.

What followed was an $115,000 study, months of work, and a 79 page report analyzing the risks of the Adelphia and Mariner East 2. G2 outlined two goals:

  • Determine the risk of fatalities in relation to distance from the pipelines
  • Examine how the risks compare to other common risky scenarios and activities

G2’s findings are eye opening:

  • A person is 20 times more likely to die from a traffic accident
  • A person is 35 times more likely to die from a house fire
  • A person is 20 times more likely to die from a fall from the stairs

In short, the report summates that “the individual fatality risk levels estimated for both the Mariner East 2 pipeline and the Adelphia pipeline fall within a range of other common risk sources.”

Fear mongering around pipelines in Pennsylvania has led to extremely exaggerated interpretations of risks. G2’s study is important in reaffirming that these pipelines have remained committed to safety through surpassing a rigorous state and federal permitting and review process.

Pipeline Opponents’ Desperation Painfully Obvious

Jim Willis, editor and publisher of Marcellus Drilling News, weighed in on the latest complaints filed by 7 pipeline opponents from Chester and Delaware counties. Specifically, Willis calls the effort to halt Mariner East 1 and 2 a ‘Hail Mary’ attempt, insisting the continued “…chutzpah of these people is breathtaking.” He is right. Pipeline opponents have tried every tactic and trick to stop an infrastructure project critical to Pennsylvania’s natural gas industry.

The PA PUC complaints have revealed interesting details about the forces and special interests at play to stop the Mariner East pipeline system.

Michael Bomstein, a local attorney with ties to the Clean Air Council (a longtime pipeline opposition group), is representing the petitioners in their complaints. Bomstein’s son, Alex, is the senior litigator with the Clean Air Council. The two have worked together to file lawsuits against Mariner East in the past and Michael Bomstein has even been recorded discussing the lawsuits against the pipeline.

The petitioners are claiming that because a supplemental line is temporarily being used to bring Mariner East 2 online until construction is completed Sunoco is not in compliance with legal guidelines and their ‘public awareness program’ must be reviewed by the PA PUC.

The PA PUC has already accepted the plan.

Additionally, the supplemental line under question has passed two hydrostatic tests – one in 2017 and another in 2018. The line has been approved for use as Paul Metro, manager of the safety division of the PUC, confirmed “No leaks were discovered in either test. If a pipeline successfully passes a hydrostatic test, it can be assumed that no hazardous defects are present in the tested pipe.”

Pipeline opponents are throwing themselves at any loophole or legal nuance where they can make claims to halt the Mariner East pipeline system without acknowledging well documented facts from state and federal regulators.

Dramatics Take Front Stage at Pipeline Study

A Daily Local News piece recently reported on the latest quantitative risk assessment study used to argue against the Mariner East 2 project. Pipeline opponents inclination to generate their own, cherry-picked studies without any credence to technical expertise or training is a farce.

The study, conducted by Del-Chesco United for Pipeline Safety’s George Alexander, was presented on Monday night at an Uwchlan Township Board of Supervisors meeting. Pipeline opposition groups were able to crowd fund thousands of dollars to secure a three month – license of CANARY, a software used to model pipeline risk, in what is now the third time a group has conducted a meaningless ‘study’ of their own on pipeline safety even though expert studies have shown little concern.

Before results were presented to Supervisors, a member of the presentation team played a dramatic video of Sutton County, Texas’ recent pipeline incident. George Alexander later admitted to trying to model the “…worst case scenario…” Attempts to fear monger could not be more obvious.

Letting a concerned civilian run wild with software reserved for engineers is not going to yield practical or accurate results.

Lastly, pipeline opponents at the presentation hoped to leave with a guarantee from the board to encourage a “state of emergency” be placed on Mariner East 2. Such a request is vastly inappropriate considering the source the foundation that the request is relied.

Pipeline opponents have tried to pursue every angle possible to inaccurately claim that the Mariner East 2 pipeline is unlike all other pipelines and would be unsafe to operate. Little do they know that similar lines run throughout Pennsylvania already. The public should acknowledge regulatory standards and company credentials before seeking a title reserved for natural disasters and drug epidemics.

Pipeline Cybersecurity A Local and National Priority

A memo leaked earlier in the year uncovered that the Department of Energy was considering a bailout for failing nuclear and coal plants, claiming a unique cybersecurity robustness not shared by natural gas pipeline systems.

The American Petroleum Institute (API) recently countered and clarified that cybersecurity remains a top priority for the natural gas industry. Proclaiming coal and nuclear plants to be more secure than their natural gas and oil counterparts is simply untrue.

In fact, many processes and standards are shared amongst natural gas, coal, and nuclear plants. Though it must be acknowledged that natural gas and oil industries uniquely benefit from robust private-public partnerships with the DOE, DHS, and FBI. As a result, cybersecurity is continuously improving thanks to a constant feedback loop from these relationships – exemplified in the layers of electronic and mechanical security measures industry wide.

API’s report indicates that cyberattacks increased 20% between 2014 and 2015; an increase was also recorded from 2015 to 2016. Of these attacks an estimated 1 in 5 specifically targeted the energy sector. The growing role natural gas plays in supporting the United States’ energy grid means pipeline cybersecurity is now a matter of national security.

Because Pennsylvania is home to an ever growing network of natural gas pipelines including Mariner East, Mariner East 2, and the Revolution system efforts should be taken at state levels to contribute to maximizing the security of these pipelines.

Pipeline opposition in Pennsylvania has previously acted to halt the construction and operation of pipelines by tampering with machinery, valve stations, materials, or baiting local wildlife into pipeline construction zones as environmental activist Ellen Gerhart has done. All of these actions unnecessarily increase pipeline vulnerability.

To combat this the Pennsylvania legislature can pass legislation like Senate Bill 652 – introduced to strengthen the consequences of tampering and trespassing on public infrastructure projects. Considering the critical role natural gas systems occupy in the national energy grid a strict punishment for endangering the grid is fully justified.

The abundance of natural resources Pennsylvania has access to will be used for decades to support the state and country’s energy grid as well as push the United States’ global energy dominance. Though Senate Bill 652 lapsed in the Pennsylvania legislature a top priority should be placed on ensuring pipeline security from local threats in the interest of preserving cybersecurity following the coming midterm elections.

Facts Must Be Acknowledged Before Ideology

Opposition to Mariner East 2 has moved from local Pennsylvania communities and into the pages of The New Yorker. Over the weekend an article from the outlet compounded on opposition narrative against Mariner East 2 but left many important facts unmentioned:

  • The Mariner East 2 pipeline is subject to rigorous permitting and safety standards including oversight from the Pennsylvania Public Utility Commission, Federal Energy Regulatory Commission, and the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration. Sunoco has remained committed to going above and beyond all safety standards throughout Mariner East 2 construction and operation.
  • 9,500 construction related jobs have been created annually during the construction process. In turn, Pennsylvania has collected upwards of $100 million dollars in taxes stemming from construction spending across the state. In all, an expected $9.1 billion will be spent in Pennsylvania throughout the construction of Mariner East 2.
  • Sunoco has conducted nearly 200 public information sessions to educate the public on the pipeline, receive resident feedback, and accommodate all needs of Pennsylvania communities.
  • Pipelines are the consensus safest transportation method for liquefied natural gas and Mariner East 2 uses the most state of the art technologies to bring safety to unmatched standards.

Mariner East 2 is a key component for Pennsylvania to realize its energy potential. Opposition groups have spun misinformation into fear in hopes of halting the project. Ignoring the facts is counterproductive to promoting public safety and undermines what local, state, and federal regulators have worked so diligently to do – ensure Mariner East 2 safely serves the Pennsylvania public.

Taxpayer Money Going to Fund Pipeline Opposition Groups

Recent work by investigative outlet, Inside Sources, shows taxpayer money was distributed from a Department of Transportation program to pipeline opposition groups. Records also suggest that leaders of pipeline opposition groups may have personally benefited from the taxpayer money.

TAG Grants, awarded by the Pipeline and Hazardous Materials Safety Administration (PHMSA), were halted in 2016 following another report from Inside Sources showing “…TAG is continuing to award grants to anti-pipeline groups in violation of its Congressional mandate.” It seems PHMSA is now back to using the same tactics:

“One of the grant recipients in the FY2018 program is the Pipeline Safety Coalition, which was given $99,938 to establish a ‘community safety awareness network’ in Pennsylvania. The Pipeline Safety Coalition has received more than $1.1 million through the TAG program in the past, despite having filed public comments against major pipeline projects in Pennsylvania.”

PHSMA admits to deeming TAG grants “low risk” but have not upheld their responsibility to ensure the money “…may not be used for lobbying, for direct advocacy for or against a pipeline construction or expansion project, or in direct support of litigation.” By providing pipeline opposition groups with funding to create and dictate misinformed narratives about pipeline projects in Pennsylvania.

The distribution of taxpayer money in Pennsylvania through TAG grants looks increasingly partisan and misappropriated after Inside Sources uncovered $50,000 awarded to the Pipeline Safety Coalition, led by Lynda Farrell, in 2012. Five months later, records show $30,000 of the award was spent at ‘Blue Heron Consulting’ – a small nonprofit run and operated out of the home of Lynda Farrell.

Distribution of TAG grant money to partisan, anti-infrastructure advocates like Lynda Farrell goes against the intent of the program. Farrell has been a known opponent to necessary infrastructure projects in the past, but somehow continues to win these grants, which pay for her anti-infrastructure agenda. What has not been proven is whether or not Ms. Farrell plans to comply with grant stipulations on this round of funding. She never proved that the funding was used accordingly in the past.

It is disappointing to see a regulator responsible for ensuring the public’s safety distribute taxpayer money so recklessly to opposition groups that only spread fear.

Sunoco and PA DEP Honor Responsibilities with Grants

The Pennsylvania Department of Environmental Protection (DEP) recently issued 61 grants to 14 different Pennsylvania counties for local infrastructure projects related to water quality, watershed restoration and stormwater management. This news is further confirmation that Sunoco and the Pennsylvania DEP remain committed to their responsibilities

Any permit violations issued against Sunoco also featured a monetary component. While the process for determining the amount is unknown Sunoco was very forthcoming in honoring this feature of their contract and willingly sent the DEP $12.6 million to be dispersed at their discretion. The DEP has decided to split the money amongst various townships in 14 of the 17 counties Mariner East 2 transverses.

DEP Secretary, Patrick McDonnell, was quoted in an article:

“…it is nice that this penalty could be put directly towards other deserving improvement projects in the communities along the right-of-way,”

It is equally encouraging to see Sunoco hold their end of the bargain by remedying any violations, bolstering safety standards and honoring their commitments. This news is proof that regulators and corporations working in tandem can benefit all parties involved. The Pennsylvania DEP has done a great job ensuring the regulatory process is effective.